EY - BorderCrossings: IRS restructuring

EY International Tax Webcast

BorderCrossings with EY's transfer pricing and tax professionals

IRS restructuring, particularly as it affects international tax enforcement

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This webcast is currently being prepared for on-demand viewing and will be available on this site soon.

The IRS’ Large Business and International (LB&I) Division recently reorganized and has a new approach to IRS international tax enforcement.

Join EY’s panel of Tax Controversy professionals, each a former IRS enforcement executive, as it discusses the reorganization and what it could mean for your business, including:

  • The new LB&I structure
  • The shifting jurisdictional lines and evolving “rules of engagement”
  • The development of issue-focused campaigns and treatments
  • The effect of the restructuring on current IRS enforcement programs, such as the coordinated industry cases (CIC) and the compliance assurance process (CAP)

The panel will also discuss recent trends in IRS litigation tactics, such as the use of designated summons and the designation of cases for litigation.

During this live, interactive webcast, EY transfer pricing professionals will take questions from the audience.

This program will be of interest to vice presidents/directors of tax/international tax/transfer pricing/customs/global trade, directors of finance, CFOs, international tax managers, and tax accountants looking for the latest practical information and guidance to support their global business initiatives. We hope you will be able to join us.

Save the date for the next BorderCrossings webcast: Transfer pricing and customs value

1:00–2:15 p.m. EDT New York/Toronto; 10:00–11:15 a.m. PDT Los Angeles/Vancouver

  • Wednesday, 27 April


Heather Maloy

Ernst & Young LLP, Tax Controversy Leader

Heather Maloy is a principal in Ernst & Young LLP’s National Tax Department in the Tax Policy & Controversy (TPC) group and serves as the US Director of Tax Controversy. Heather assists clients in working more effectively with the Internal Revenue Service (IRS) to achieve tax certainty by developing tax audit management strategies to resolve tax disputes and mitigate future controversy.

Before joining EY in 2015, Heather served for almost six years as the IRS Commissioner for the Large Business & International (LB&I) Division. Heather was responsible for developing and driving several innovative approaches to resolving compliance issues, including reinvigorating the Industry Issue Resolution Program, making the Compliance Assurance Process permanent, and providing examiners guidance through LB&I Directives on topics such as the Economic Substance Doctrine, Section 475 (Mark-to-Market) and Section 199 (Domestic Production Deduction). She also drove exam process improvements through the creation of a robust peer review process and Lean Six Sigma applications. Changes included the phasing out of the Tiered Issue Process and developing a new Information Document Request (IDR) process.

Heather earned her BBA in Accounting from Emory University, her JD from Cornell University Law School, and her LLM in Taxation from the University of Florida College of Law — where she also served as an Assistant Professor.

Linda Kroening

Ernst & Young LLP, Business Tax Advisory

Linda Kroening is an executive director in Ernst & Young LLP’s National Tax Department in the Tax Policy & Controversy (TPC) group. Linda assists clients in working more effectively with the Internal Revenue Service (IRS) to achieve tax certainty by developing tax audit management strategies to prevent, manage, and resolve tax disputes and any future controversy.

Before joining EY in 2016, Linda served for almost six years as the Division Counsel for the IRS Large Business & International (LB&I) Division. In that role, Linda led a team of more than 300 attorneys and paralegals responsible for providing all aspects of technical legal advice and litigation for LB&I. She was directly involved in the design and development of LB&I Industry Issue Resolutions (IIRs) including those relating to bank and insurance company debt and hedging transactions, and power generation and telecommunication company tangible property capitalization issues. Linda was also instrumental in the development of the LB&I Directive on the codified economic substance doctrine, LB&I’s implementation of the Affordable Care Act provisions regarding the branded pharmaceutical fee, and the redesign of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) rules regarding partnership audits.

Linda earned her BS in Biology from Marquette University and her JD from the University of Wisconsin School of Law.


Craig Sharon

Ernst & Young LLP, Transfer Pricing

Craig Sharon is a member of Ernst & Young LLP’s Transfer Pricing practice. He is based in Washington, DC, but spends considerable time on the west coast.

Craig practices in all aspects of transfer pricing planning, compliance, and controversy and has particularly deep experience with advance pricing agreements (APAs) and competent authority proceedings. Prior to joining Ernst & Young LLP in May 2013, Craig served as the IRS APA director from 2008 to 2011. As APA director, Craig was a member of the senior executive team within the IRS Office of Associate Chief Counsel (International) (ACCI), and in his last year with the IRS, Craig was intimately involved in the development of the restructuring plan that led to the creation of the IRS Large Business & International (LB&I) Division and the merged Advance Pricing Agreement and Mutual Assistance (APMA) Program.

Craig received his BA in Economics from the University of Idaho and his JD from Georgetown University Law Center. He was an adjunct transfer pricing professor in the graduate tax program at Georgetown law from 2006 to 2012. Craig is also a frequent writer and speaker on transfer pricing and related international tax issues.